ML20136D614
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.r March 11, 1985 s
REVIEW OF COST BURDEN ASSOCIATED WITH 10 CFR'50 REGULATORY REQUIREMENTS p; red by:
" COST ANALYSIS GROUP OFFICE OF RESOURCE MANAGEMENT
- i. Nuclear Regulatory nmission 84 e
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0511210333 851022 PDR FOIA BELL 85-361 PDR
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This Report is in response to the Office of Administration's request for the Cost Analysis Group's (CAG) review of the cost burden associated with 10 CFR 50 regulatory requirements.
It appears that the complete report adequately addresses the factors of The points and questions our review raises however are more detailed concern.
and item specific. A key problem throughout the report is the inconsistency in use of data.
For example, the number of operating nuclear power plants varies from approximately 70 to 104. The report also varies in its use of the cost of staff per time period (e.g., cost estimates for government staff per year range from $84,000 to almost $125,000).
Somewhat related is the incon-1 sistency in the inclusion of dollar estimates in the estimated respondent burden sections of the report. Another problem throughout the report was the lack of discounting of any future costs.
Lastly, there seems to be a general misunderstanding throughout the report because of the incorrect, interchange-able use of licensee, nuclear power plant, and site.
There may be more than one nuclear power plant at a site (e.g., Calvert Cliffs 1 and 2).
Also, a licensee may have more than one plant or site (e.g., Cenxonwealth Edison has i
the multiplant Quad Cities and Dresden Sites).
The specific comments follow:
Summary of Supporting Statement:
This table should include the units in the caption, such as "(in staff hours)."
The Total Annual Recordkeeping Burden reported as 577,095 on page vi, actually sums to 576,695.
Also, see comments relating to page 31.
Page 11 Estimated Cost to the Government is lacking detail. No infonnation is provided as to how the "4 man-years" estimate was obtained.
i-Also, since this is the first part of many, it would be beneficial
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to state explicity that a $100,000 per staff-year cost is being assumed for government employees.
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Page 20 Description of Survey plan there are 85 operating licensed power reactors, not licensees, i.e., some licensees have more than one licensed power reactor.
The last line on the page is confusing..It should be rewritten as:
"42 sites X'1400 staff hours / site - 3200 staff hours (for the deletion of water quality requirements)".
Page 21 Total Burden is reported to be 391,930 staff-hours. Our summation resulted in 326,280 staff-hours.
Page 23 The $20 per hour rate with the 100% added for overhead is not equal to the $60 figure quoted.
I The 19,180 staff-hours value is not reproducible. Our sum is 17,100 -
staff-hours.
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2-i One Page 11, a $100,000 per staff year figure was implied for government costs, however, the $60 per staff hour figure used here compares more favorably to $125,000 per staff year cost.
4 There should be some additional information provided on the origin of the $600,000 figure for Technical Contract Cost.
Page 27 A figure of 84 operating NPP's is used here versus the other values cited elsewhere.
The "four large test reactors" should be defined, as the most recent NRC listing, NUREG-0020, Vol. 8, No.12, lists 57 research reactors, 1
2 experimental and test reactors, and 3 critical experiment facilities. Which group are the 4 from?
i The statement "133 11censees" is incorrect.
Suggest using 133 reactors.
Page 31 The $864,000 estimated cost to the Government is wrong by an order i
of magnitude.
12 X 12,000 = 144,000.
144,000 X $60 = $8,640,000, i,
This error carried over to the Summary Table and is incorrect there as well.
The equation within the parentheses is mathematically incorrect.
Ignoring the units 12 X 12,000 does not equal 144,000 X 60.
Page 33 Estimate of Respondent Burden for part 50.48 under "No. of Respondents affected" contains a typo in that " Fewer that..." should read " Fewer than..."
Page 34 Last line mathematically incorrect; 95 X 5 does not equal 475 X $60.
Page 36 Estimate of approximately 70 nuclear power reactors is too low.
Compare with other estimates in your study.
Page 39 Fourth paragraph, First line typo:
License" should be " Licensee".
Page 40 Cost estimate in first paragraph implies 84 reactors, but incorrectly refers to costs "per site".
Second paragraph in parentheses, insert " amendments" between "3" and "per."
Page 43 "Approximately 80 licensees".
Page 47 Third paragraph second line replace "no" with "not".
Page 50
".. 84 operating nuclear priants."
Page 52 2.a. (1) speaks of "approximately 75 nuclear power stations (April 1985 - 1986) holding an operating Ifcense." Also, states there will be 78 by April of 1988.
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These numbers are inconsistent with most of the other parts of this report as well as NRC's numbers.
i Page 53 Costs to be incurred in future years are not discounted.
Through Page 60 Page 62 Uses 84 as number of licensees.
Page 66 Cost to the Federal Government estimates imply an hourly staff cost of 545 compared with using 560 per staff-hour elsewhere in this report.
Page 75
- 3. Estimate of Burden uses a cost of $140,000 per person-year, most other sections use lower values.
- 4. Government Cost implies a cost of a government staff year of 584,000, mucn lower than the values used in other parts of the report.
Page 80 Uses 82 as the number operating nuclear power plants.
No discounting of costs occurring in future years.
Page 84 States that there are "..
72 operating nuclear power plants and 60 plants to be licensed in the future..."
Page'91 2.a. This section reports that there are approximately 70 commercial 3
nuclear power plants.
Page 92 3.a. indicates there are approximately 77 licensees, Page 96 1.a. states "..
104 nuclear power plants to be operating when the rule becomes effective in 1984."
Page 118 2 (A) Approximately 90 reactors and about 35 plants are currently under review.
Page 121 No discounting of costs occuring in future years Page 122 (c) (1) uses a staff year cost estimate to licensees of $120,000.
Page 123 Uses a federal' government staff-hour estimate of $60.
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